It is clear that he has violated 11 CFR 100.72, the "testing the waters" provision of FEC law. Accordingly, his failure to file disclosure reports violates the law, and the Commission should demand full disclosure of Mr. Thompson's campaign fund raising and expenditures, as well as penalize Mr. Thompson for his willful violation of the law.

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Mr. Thompson had approximately $2.8 million in his campaign account after the IRS filing. This fact also clearly indicates that he did not intend to use this money for 'exploring' a possible candidacy. Otherwise, it would have been spent on exploratory activities, especially given the documentation of his impending announcement of candidacy.

could be taken to investigate Thompson, as i understand it, because he is currently operating under a 527 group, which is outside FEC oversight. the IRS could have filed a complaint, but, again as i understand it, a third party had to bring the complaint to the FEC.